Lalic v Revenue & Customs (INCOME TAX/CORPORATION TAX : Assessment/self-assessment) [2018] UKFTT 618 (TC) (15 October 2018)
The Tribunal refused permission to appeal out of time due to lack of reasonable excuse, significant delay, absence of merit in the substantive appeal, and the overriding need for finality and certainty in tax matters.
- Citation
- [2018] UKFTT 618
- Parties
- Appellant: Michael Lalic; Respondents: The Commissioners for Her Majesty’s Revenue & Customs
- Jurisdiction
- United Kingdom
- Judgment Date
- 15 October 2018
- Procedural Posture
- Income Tax Assessment and Penalties Appeal / Application for Permission to Appeal Out of Time
- Outcome
- Application for permission to appeal out of time refused.
- Legal Topics
- Income Tax, Self Assessment, Penalties, Late Appeal, Tribunal Procedure
Case Brief
Summary, issues, holding and outcome
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Parties
Michael Lalic
Appellant
The Commissioners for Her Majesty’s Revenue & Customs
Respondents
Procedural Posture
Income Tax Assessment and Penalties Appeal / Application for Permission to Appeal Out of Time
Legal Issues
- 1 Whether the appellant should be granted permission to appeal out of time against HMRC's assessments and penalties for inaccuracies in self-assessment returns for 2011-12 and 2012-13
Ratio Decidendi
The Tribunal refused permission to appeal out of time due to lack of reasonable excuse, significant delay, absence of merit in the substantive appeal, and the overriding need for finality and certainty in tax matters.
Court Disposition
Application for permission to appeal out of time refused.
Orders
- Appeal not admitted.
Full Case Text
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